re: interim remedial action report · 2020. 6. 7. · 5.6 lessons learned 5-9 ... observed improper...

IIIm Interim Remedial Action Report

Ace Services SiteI Colby, Kansas

IIm Prepared for

USEPA Region VII

I

• September 15,2003

I

™ Prepared byBlack and Veatch Special Projects Corp.

I_ EPA Contract Number 68-W5-0004I EPA Work Assignment Number 061-RARA-07GE* BVSPC Project Number 46129

( Approved: _^-?—~/^ —7

• Sup&r^fund Divife^erfCecilia.Japja^ActlMg DirectorSup&r̂ fund DivisionU.S. Environmental Protection Agency, Region VII

2003SUPERFUND DIVISION

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Table of Contents

1.0 Introduction and Background 1-1

1.1 Site Location 1-1

1.2 Site History 1-1

1.3 Contaminants and Clean up goals 1-3

1.4 Site Remedial Action Scope Elements 1-31.4.1 Demolition Package 1-41.4.2 Construction Package 1-4

7.5 Subcontracting 1-51.5.1 Demolition Package 1-51.5.2 Construction Package 1-5

2.0 Facility Description 2-1

3.0 Remedial Action Chronology 3-1

4.0 Perfomance Standards And Quality Assurance 4-1

4.1 Subcontract Specifications and Drawings. 4-1

4.2 Project Plans .4-1

4J Scheduline 4-2

4.4 Submittals and Shop Drawings 4-3

4.5 Meetings 4-3

4.6 Site QC and Documentation 4-4

4.7 Monthly Progress Reports 4-5

5.0 Remedial Action Construction Activities 5-1

5.1 Construction Progress and Milestones 5-7

5.2 Construction Health and Safety 5-2

5.3 Testing and Start-up '. 5-3

5.4 Construction Subcontract Change Orders 5-5

5.5 Problems Encountered and Met 5-7

5.6 Lessons learned 5-9

6.0 Certification that Remedy is Operational and Functional 6-1

7.0 Operation and Maintenance 7-1

8.0 Summary of Project Costs 8-1

GWTSRA Report TC-1 46129.150RAC Vll Ace Services Site September 2003

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9.0 Bibliograghy 9-1

Appendix A

Appendix B

Appendix C

Appendix D

Appendix E

Appendix F

Appendix G

LIST OF APPENDICES

Project Schedule

Submittal Register

BVSCP Resident Inspector Daily Reports

FHI Daily Reports

Construction Photos

Monthly Construction Progress Reports

Job Hazard Analysis (JHA)

GWTS RA ReportRAC VII Ace Services Site

TC-2 46129.150September 2003

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1.0 Introduction and Background

The U.S. Environmental Protection Agency (USEPA) has completed remedial

action (RA) efforts for the buildings at the ACE Services Site in Thomas County, Colby,

Kansas. This Remedial Action Report documents the activities undertaken by Black &

Veatch Special Projects Corp. (BVSPC) under contract with the USEPA to facilitate the

construction of a groundwater treatment plant (GWTP) for the purpose of removing

hexavalent chrome (Cr+6) from the groundwater. The groundwater remedial action was

divided into two phases, demolition and construction. This report documents the

construction effort. The demolition effort is documented in the ACE Services Site

Remedial Action Report, Demolition Summary (BVSPC 2003a).

This remedial action report has been prepared under USEPA RAC Contract No.

68-W5-0004, work Assignment No. 061-RARA-07GE.

1.1 Site Location

The ACE Services site is located near the edge of Colby, Kansas at 500 East

Fourth Street in Thomas County. The geographic coordinates for the site are

approximately 100°02'lO" West Longitude and 39°23'47" North Latitude. The site lies

in the southwest quarter of Section 31, Township 7 South, Range 33 West. The facility is

next to a small church and a hardware store. The Thomas County courthouse is

approximately 2-1/2 blocks west of the site. The surrounding area is primarily light

industrial and commercial, although there are a few residences within two blocks.

1.2 Site History

Northwest Manufacturing Company operated a plating facility at the site from

1954 to 1969. ACE Services was formed in 1969 and operated a chrome electroplating

operation at the site through 1989. The site included two buildings, the plating shop

building and an office/machine shop building. The plating building featured three

concrete/cinder block troughs where vats of plating solution were located during

operations. The Kansas Department of Health and Environment (KDHE) first began an

investigation into improper plating waste management practices by ACE Services in

1971. In 1975 a wastewater treatment facility (WWT) was erected on the east side of the

plating building. Plating waste was subsequently treated in the WWT and discharged to

an unlined evaporation lagoon to the east of the plating building.

In 1980 elevated chrome levels were detected in Colby Public Water Supply well

PWS-8 located about V* mile east of the ACE site and in other nearby private wells.GWTSRA Report 1-1 46129.150RAC VII Ace Services Site September 2003

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PWS-8 was removed from service. During a follow up investigation KDHE again

observed improper waste handling practices. Additionally, lead and chromium

contamination was found in the lagoon soil. KDHE and the City of Colby contracted the

excavation of 500 to 1000 cubic yards of contaminated soil from the lagoon area.

In 1988 KDHE issued an Administrative Order requiring ACE Services to clean

up the site. ACE did not comply with that order. ACE terminated operations at the site

in 1989 after losing corporate status due to failure to pay taxes and fees.

In 1992 KDHE coordinated the removal of plating wastes from the plating shop

building. Investigations undertaken as part of this removal determined that the floors and

walls of the troughs were contaminated with lead and chromium. It was further

determined that the contamination may have migrated into the underlying soils. This

assessment also found that elevated levels of lead and chromium were still present in the

lagoon soils east of the WWT.

In 1994 the USEPA conducted a remediation effort to clean up the contaminated

soils, concrete and structures at the site. This action established clean up goals for soils

of 1500 mg/kg total chrome and 500 mg/kg total lead. The WWT was demolished and

removed in this action. The walls and floors of the three plating troughs were removed

and the underlying soils were excavated. Not all of the contaminated soils could be

removed at that time due to concerns for undermining the building structure. Once the

contaminated soils that could be accessed were removed, the trough excavations were

backfilled with clean soil and topped with concrete even with the remaining floor slab in

the building.

As part of the 1994 remediation, an attempt was made to reduce the Cr+6 in the

surface layer of the concrete floor slab to less toxic Cr+3 by applying a sulfuric acid

solution followed by sodium metabisulfite. The 1994 clean up also included an

assessment of the lagoon area which determined that there were soils contaminated in

excess of the clean up goals. Approximately 500 tons of soil were excavated from the

lagoon and disposed of.

The ACE Site was added to the National Priority List (NPL) in September 1995.

Sampling conducted in 1996 and 1999 indicated that areas of the plating shop floor slab

surface were still contaminated. These areas were scarified (progressively ground down)

removing approximately linch from the top of the concrete surface.

The Ogallala Aquifer underlies the area in and around Colby. A portion of this

aquifer has been contaminated with hexavalent chrome from releases at the ACE site.

Extensive groundwater sampling was performed from 1980 through 2000 with much of

the sampling being done between 1996 and 2000. The sampling efforts indicated that the

chromium plume is approximately a mile long, 1A mile wide and 130 feet thick with the

GWTS RA Report 1-2 46129.150RAC VII Ace Services Site September 2003

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western edge of the plume beginning in the proximity of the ACE site. Concentrations of

Cr+6 in the plume range up to about 4,000 ug/1. The Record of Decision (ROD) requires

remediation of the groundwater chrome plume to the maximum contaminant level (40

CFR 141.62) of 100 ug/1 total chromium. The prescribed method of remediation is a

pump and treat system utilizing ion exchange to remove chrome from the extracted

groundwater to below 17 ug/1 hexavalent and 100 ug/1 trivalent chrome.

Design of the pump and treat system was completed by BVSPC in January 2002.

Prior to beginning construction, the existing machine shop, plating shop and underlying

concrete slabs were demolished and removed. The demolition work also included

removing the remainder of the contaminated soil from the site. This demolition effort is

fully documented in the Demolition Summary Report (BVSPC 2003a).

1.3 Contaminants and Clean up goals

The only site groundwater contaminant is chrome. No chrome state other than

hexavalent has been found in the plume. As noted in the site history above, the ROD

established clean up goals for the pump and treat system as follows:

Ground Water: 100 ug/1 (ppb) Total Chrome

Treatment System Maximum Discharge: 17 ug/1 (ppb) Hexavalent Chrome100 ug/1 (ppb) Total Chrome

1.4 Site Remedial Action Scope Elements

The design of the treatment system for remediating the groundwater chromeplume included a new treatment building of approximately 10,000 square feet attended

by two 250,000 gallon water storage tanks and access/parking for 18 wheel tractor trailer

trucks for resin exchange service. The ACE site was selected as the most beneficial

location for the new treatment facility. Utilizing this site required demolition of the

plating building, the machine shop building and the abandon gas station. A demolition

subcontract package was prepared as part of the overall groundwater remedial design and

bid as a separate contract under Work Assignment No. 039-RDRD-07GE. Prior to

bidding of this subcontract the trustee for the ACE site removed the structures of the

plating and machine shop buildings for scrap salvage. Also, KDHE performed the

removal of the underground fuel storage tanks at the abandon gas station. A separate

construction package was prepared under the remedial design (RD) Work Assignment for

construction, testing and start-up of the extraction and treatment system. The principle

scope elements for the two packages are presented below.GWTS RA Report 1-3 46129.150RAC VII Ace Services Site September 2003

I1.4.1 Demolition Package

I The principal scope elements for the demolition work included:

II . Removal of a small amount of asbestos-containing caulk around the doors and

windows of the old gas station.

2. Demolition of the old gas station.

• 3. Removal of the pavement surrounding the gas station, plating shop and machine shop.

I 4. Removal of the concrete rubble and trees on the eastern down-slope side of the site.

5. Tear-out and removal of the plating shop and machine shop concrete floor slabs and• foundations.

6. Hauling and disposal of all the debris, asphalt and concrete from scope items 2• through 5 above.

7. Excavation, transportation and disposal of approximately 1 000 cubic yards of soil• contaminated with hexavalent chrome from around the former troughs and foundation

piers in the plating shop.

I 8. Backfill of excavated areas with clean soil compacted to minimum 90% proctor.

_ The intent of the demolition subcontract scope was to clear and prepare the site

| for construction and remove the remaining contaminated soil from the site. Execution of

the demolition work during completion of the construction design and bidding of the

• construction subcontract allowed for completion of the construction phase several months

earlier than if the demolition and construction had been bid together. Complete details of

• the demolition phase are provided in the Demolition Summary Report (BVSPC 2003a).

1 .4.2 Construction Package

The principal scope elements for the construction phase included:

• I . Over excavation of the treatment plant and storage tank foundations and backfillingwith structural compacted fill.

2. Concrete foundations for the storage tanks, GWTP building, and process trains.

• 3. Erection of two 250,000 gallon above ground water storage tanks.

GWTSRA Report I -4 46 1 29. 1 50RAC VII Ace Services Site September 2003

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4. Erection of a new 10,000 square foot metal building to house the treatment process.

5. A new 1000 gallon per minute (gpm) ion exchange treatment process with allattending subsystems, pumping and controls.

6. A dual discharge system from the effluent storage tank to allow treated water to bedischarged to either the nearby creek or to the City of Colby drinking water system.

7. Installation of 12 new ground water extraction wells with above ground wellenclosures as well as refurbishment of one former public supply well (PWS-8) as a13th extraction well.

8. Approximately one mile of buried high-density polyethylene (HOPE) pipeline.

9. Programmable Logic Control (PLC) based control systems for all new systems.

10. Start-up and testing of the new extraction and treatment systems.

1.5 Subcontracting

1.5.1 Demolition Package

Eight companies (all small businesses) were invited to bid on the demolition

subcontract. The lowest responsive bidder was Woofter Construction & Irrigation Inc.

(Woofter) of Colby, KS. The subcontract was structured as a lump sum subcontract with

unit prices given for any necessary quantity adjustments for contaminated material

removal, transportation and disposal as well as for quantity changes in asbestos removal.

Notice of award was given to Woofter on January 8, 2002. Notice to proceed was given

to Woofter on February 7, 2002.

15.2 Construction Package

Five companies (all small businesses) were invited to bid on the construction

subcontract. Only two bids were received. The two initial bids were both judged to be

non-responsive. The job was bid a second time and two satisfactory bids were received.

The lowest responsive bidder was Ferguson Harbour Inc. (FHI) of Hendersonville,

Tennessee. The subcontract was structured as a lump sum with unit prices given for

selected elements that had the potential for quantity adjustments such as pipeline length

or well depth. Notice of award was given to FHI on April 19, 2002. Notice to proceed

was given to FHI on May 28, 2002.


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2.0 Facility Description

The new ground water treatment system (GWTS) consists of a ground water

extraction system and a treatment plant. The ground water extraction system is

comprised of a total of 13 extraction wells screened in shallow, intermediate and deep

zones of the aquifer. Twelve of the wells are new and one (PWS-8) is a former public

water supply well that was taken out of service due to chromium contamination. This

well was retrofitted as an extraction well for the remediation system. The locations of the

extraction wells were determined via computer flow modeling during the design phase to

optimize control and capture of the chromium plume. Each well head is enclosed in a

small heated and ventilated well house building. The well house also contains the motor

control center, PLC remote terminal unit (RTU) cabinet, flow meter, modulating flow

control valve and all other piping, electrical and control appurtenances for the well. Each

well pumps into a buried HDPE pipeline system, which conveys the water to the influent

storage tank at the new GWTP. Each well is controlled from the PLC system in the main

office at the GWTP via a fiber optic link.

The new treatment plant is provided with two 250,000 gallon above ground

storage tanks. One tank stores raw ground water from the extraction wells and the other

stores treated water from the GWTP. The tanks provide about 4 hours of storage capacity

to allow for flow balancing in the treatment system.

The new GWTP uses an ion exchange system to remove hexavalent chrome from

the extracted ground water. The ion exchange system consists of two parallel process

trains, each consisting of three ion exchange beds. Each bed is loaded with 560 cubic

feet of Type II strong base anion exchange resin in chloride form. As water passes

through the bed the hexavalent chrome (as chromic acid) is exchanged for a chloride ionin the resin. Each three-bed train can be operated independently at any flow rate selected

by the operator. The ion exchange system operates in a lead-lag configuration to

providing full redundancy to assure that effluent quality is always met. In each train,

contaminated ground water flows through the lead bed where the chrome is removed.

The water then flows through a lag bed, which serves as redundant backstop in case there

is some chrome breakthrough from the lead bed. The third bed in each train is in

standby. Water does not flow through the standby bed. When the resin in the lead bed

becomes fully saturated with chrome, the beds are advanced so the lag bed goes into lead

service and the formerly standby bed goes into lag service. The spent resin in the former

lead bed is then removed and replaced with new virgin resin and that bed is placed in

standby. Each process train is designed for a nominal flow of 500 gpm giving the plant a

nominal capacity of 1000 gpm. Final testing of the treatment system demonstrated that


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the actual capacity of the completed system is in excess of 1100 gpm (BVSPC 2003b).

A pair of raw water pumps (one per train) draws contaminated ground water from

the influent storage tank and pumps the water through a 5 micron filter then through the

treatment train and out to the effluent storage tank. Back wash, air bump, rinse, recycle,

sluicing and transfer vessel systems are provided to facilitate resin management and

transfer.

The treatment plant has large overhead doors at opposite sides which allow a full

size 18 wheel tanker truck to park inside the building for resin transfers. This allows for

the transfer of spent resin to a waste tanker and transfer of fresh resin from a tanker

directly to and from the process vessels during any kind of weather and at any time of

day.

The treated water effluent storage tank is provided with a dual out-fall. The

primary means of discharge from the effluent tank is via a gravity discharge to the

adjacent tributary to Prairie Dog Creek. Alternatively, a pair of treated water pumps are

provided to pump the effluent tank directly into the City of Colby drinking water system

if approved by KDHE. A chlorination system is provided to chlorinate water pumped to

the city system.

GWTSRA Report 2-2 46129.150RAC VII Ace Services Site September 2003

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3.0 Remedial Action Chronology

This section presents a chronological summary of the remedial activities

performed thus far at the ACE Services site to accomplish the objectives specified in the

ROD. BVSPC performed the remedial design for the site under Work Assignment No.

039-RDRD-07GE. The remedial action was performed by BVSPC under Work

Assignment 061-RARA-07GE.

Following signing of the amended ROD, the USEPA issued the RD work

assignment to BVSPC. The RD was prepared in two separate packages, one for

demolition and site preparation and the other for construction of the GWTS. The scope

elements for these two packages are listed in section 1.4 above.

The design of the demolition package was completed and bids received, evaluated

and accepted for subcontract by January 2002. All of the work in demolition phase was

completed by May 2002.

The design of the construction package was completed and bids received,

evaluated and accepted for subcontract by April 2002. BVSPC awarded the contract to

FHI and a pre-construction meeting was held on May 15, 2002. Representatives of

USEPA, BVSPC, FHI and a few critical lower tier subcontractors attended the pre-

construction meeting. Notice to proceed was given to FHI on May 28, 2002. FHI

mobilized to the site in late May and the BVSPC resident inspector was on site by June 4,

2002. Construction activity lasted for a period of 14 months. USEPA conducted a pre-

fmal inspection on April 16, 2003. The new GWTS was ready to begin the final long

duration performance test (BVSPC 2003b) on June 13, 2003. The test was completed on

July 18, 2003. USEPA conducted a final inspection on August 12, 2003 and the GWTS

was turned over to the long-term operator that same day. Operation of the GWTS forlong term remediation began at 9:00 am on August 12, 2003. BVSPC and FHI

demobilized from the site on August 13, 2003.

It is estimated that remediation of the entire plume to the clean up goal of 100 ug/1

total chrome will require 13 years from initiation of system operation.

GWTS RA Report 3-1 46129.150RAC Vll Ace Services Site September 2003

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4.0 Performance Standards and Quality Assurance

4.1 Subcontract Specifications and Drawings

The complete, detailed specifications and drawing packages prepared during the

RD provided the technical standards, construction details, performance requirements and

submittal requirements for the construction subcontract. These drawings and

specifications cover all aspects of the GWTS. These packages formed the basis of the

construction subcontract.

4.2 Project Plans

Several plans were prepared and approved by USEPA to assure the work was

done safely and adhered to the required performance and quality standards. These plans

included the following:

Quality Assurance Project Plan (QAPPV. The remedial action QAPP (BVSPC

2002a) prepared for the project was approved by USEPA, the BVSPC Program Manager

and the BVSPC Quality Assurance Manager. The QAPP established quality standards

for all sampling, data acquisition, sample analysis and assessments for the RA project.

The QAPP also defined the project organization and responsibilities for key project

personnel as well as training and documentation requirements.

Field Sampling Plan (FSP): The remedial action FSP (BVSPC 2002b) defined all

of the specific methods and procedures for sample collection in the field. The FSP also

provided the methods for sample documentation, numbering, labeling and preparation for

shipping. Methods for disposal of wastes related to sampling activities were also

provided in the FSP.

Construction Management and Quality Assurance Plan (CMP): The remedial

action CMP (BVSPC 2002c) provided the detailed methods, tool and procedures for

facilitating the management of the construction project. The CMP provided the

following:

Lines of responsibility and authority for the construction project includingBVSPC, the construction subcontractor FHI, and regulatory agencies.

Requirement for meetings and communications.

- Quality assurance requirements for the subcontractors and suppliers,submittals, inspections, tests, reporting and documentation and enforcementactions.

- Documentation requirements including daily record keeping, monthlyprogress reports, photographs, and lab reports.


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Health and Safety Program (HSP): The BVSPC HSP (BVSPC 200la) prepared

for the RA project was reviewed and approved by the BVSPC health and safety manager.

This plan covered all aspects of job safety for all the types of construction and related

activities that were to take place during the project. The BVSPC HSP was incorporated

into FHI's subcontract. In addition, FHI was required to prepare a HSP, which was

reviewed and approved by the BVSPC health and safety manager. FHI was required to

keep a full time health and safety officer at the job site and to conduct a safety meeting

each day attended by everyone on the site. The BVSPC resident inspector and

construction manager were also trained, experienced construction health and safety

experts.

FHI Work Plan: FHI prepared and continually updated a work plan which

defined the methods and safety measures they intended to employ to execute each

element of the work. Work was not begun on any element prior to BVSPC review and

approval of FHI's work plan for that element.

4.3 Scheduling

Contract Specification Section 1320 Project Schedule, specified requirements for

preparation and maintenance of a detailed construction schedule. The construction

schedule was prepared using Primavera P3. Primavera is an extremely detailed and

powerful scheduling program. FHI retained the services of a scheduling consultant to

develop and maintain the project schedule. The initial construction schedule was

reviewed by BVSPC and approved after revision. The complete detailed schedule broke

the construction project into over 500 separate activities each with defined durations

required start dates and interdependencies to other activities. The schedule included all

major procurement and submittal activities in addition to field construction activities.

The schedule identified the activities that together formed the critical path to completion

(the train of interdependent activities that take the longest time to complete) and

determined float values for all other activities.

The schedule was updated to reflect actual progress and any delays or changes in

the project on a monthly basis. A schedule update presentation was made each month

during the monthly site coordination meeting. The approved schedule update was used as

the basis for progress payments to FHI throughout the job. A copy of the last schedule

update showing the actual progression of construction is included in Appendix A.


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4.4 Submittals and Shop Drawings

The construction specifications set extensive submittal requirements for the

construction subcontractor to assure that all project elements were completed as required

by the contract. Detailed shop drawings identifying all relevant features, materials,

performance capabilities and adherence to all specified national standards were submitted

for every element of the project. Shop drawings were required for all equipment, piping

systems, building structures and components, concrete mixes and forms, controls,

instruments and any miscellaneous appurtenances. All shop drawings were reviewed by

BVSPC technical experts for conformance to all requirements. Any incomplete

submittals or submittals that failed to demonstrate complete compliance with all specified

requirements were returned to FHI for correction. FH1 was prohibited from procuring

materials or equipment prior to approval of the relevant shop drawings.

In addition to shop drawings, FHI was required to submit material certifications,

welding certificates, training certificates and other documents .to demonstrate that the

materials used and the specialized personnel employed met all the required standards.

FHI was also required to submit test reports for soil compaction tests, concrete

compressive strength test, pipe and tank leak and pressure tests, etc. to demonstrate that

these elements, once installed, met the performance criteria in the specifications.

A submittal register was prepared at the beginning of the project to track all of the

required submittals. The register was updated regularly (generally on a weekly basis) to

keep it current. A copy of the submittal register is included in Appendix B.

4.5 Meetings

Regular meetings were held to assure good communications at all levels. A

meeting was held each morning at the job site prior to any work beginning that day. TheBVSPC resident inspector, FHI project staff and all lower tier subcontractors were

required to attend the daily meeting. The daily meeting covered the work to be done that

day, any deliveries expected at the site, any problems or issues that needed to be

addressed and the expected weather for the day. The daily meeting also included a safety

briefing. In addition to the daily meetings, preparatory meetings were held each time that

a new phase of work (such as tank erection) was to begin. The preparatory meetings were

used to review the work plan, discuss the methods to be used, insure that all safety

measures were in place and provide documentation of proper planning.

In addition to the daily, safety and preparatory meetings, a coordination meeting

was held once a month at the site. FHI site and management personnel, BVSPC resident


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inspector, BVSPC site/project manager, and representatives of the USEPA attended the

coordination meetings. Representatives for KDHE and the City of Colby also

periodically attended the monthly coordination meeting. This meeting provided a forum

for all parties involved in the project to be updated regarding construction progress,

submittals progress, upcoming work, project safety issues and any significant problems

that may have come up. A presentation and review of the most recent project schedule

update was given by the scheduling consultant at each meeting. This meeting allowed all

involved to have regular input into planning and decision making for the project.

4.6 Site QC and Documentation

BVSPC had a full time resident inspector (RI) at the job site. The resident

inspector's primary task was to ensure that work done each day was in compliance with

all requirements. The RI was also responsible for enforcing the requirements of the

BVSPC Health and Safety Plan. The RI logged in all submittals and maintained the

submittal register. The RI also collected the required routine documentation from the

construction subcontractor. The RI prepared a daily report summarizing the day's

activities, lower tier subcontractors on site that day and noting any problems or delays

that may have occurred. Copies of the BVSPC RI daily reports for the entire construction

project are contained in Appendix C.

The BVSPC Construction Manager and Site Manager made periodic visits to the

site to inspect the work, conduct safety audits and review project documentation. In

addition, discipline engineers and other technical experts were on site at selected times to

supplement the RI and assist with resolving technical issues, and assist with testing and

troubleshooting. The same RI, Site Manager, Construction Manager and technical experts

were used throughout the project to provide continuity and retain the knowledge and

experience gained.

FHI had a full time project QC officer at the job site throughout the project. The

FHI QC officer worked closely with the BVSPC RI on a daily basis to enforce the

contract requirements, discover defective or non-compliant work and be sure that

appropriate corrective action was taken. FHI was required to submit a daily project

report summarizing that day's events and project progress noting any delays or problems

encountered and listing the personnel and lower tier subcontractors on site. FHI

maintained a daily site sign-in sheet and submitted it to the BVSPC RI with each daily

report. Copies of FHI's daily reports are contained in Appendix D. FHI was also

required to take photos of the site and partially completed work regularly to document

progress and provide a photographic record of the project. Selected photos depicting the


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project at different levels of completion are shown in Appendix E.

4.7 Monthly Progress Reports

BVSPC prepared a monthly construction progress report for submission to the

USEPA and KDHE. The monthly progress reports summarized construction progress for

the month, expected progress for the next month, the status of critical submittals and any

significant problems encountered. The monthly report also provided a brief analysis of

the most recent Primavera schedule update. The BVSPC Site Manager prepared these

reports. Copies of all the monthly construction progress reports are included in Appendix

F.

GWTSRA Report 4-5 46129.150RAC Vll Ace Services Site September 2003

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5.0 Remedial Action Construction Activities

5.1 Construction Progress and Milestones

The notice to proceed with construction was given to FHI on May 28, 2002. The

subcontract awarded to FHI required that the project reach substantial completion in 9

months (defined as ready to begin the required final performance test) and attain final

completion (defined as ready for final payment) within 10 months. The original

approved project schedule, therefore, set the deadline for substantial completion as

February 28, 2003 and final completion as March 28, 2003. Throughout the entire

duration of the project the weather was vary favorable resulting in a total of only 6 days

of weather delay. This moved the substantial and final completion dates to March 6 and

April 6 respectively. FHI was unable to meet these dates. The problems that resulted in

FHI schedule slippage are summarized in Section 5.4 Problems Encountered. FHI

attained substantial completion on June 13, 2003 and final completion on August 12,

2003. The total construction duration including all testing was 14 !/2 months.

A time line of construction progress and milestones is provided below:

- Notice to proceed given on May 28, 2002

- Mobilization to site was completed by mid June 2002.

- Primary earth work at GWTP site including over excavation and structural fillwas completed in July 2002.

The foundations for the storage tanks and GWTP building were completed bythe end of August 2002.

Drilling of all the extraction wells was completed in September 2002.

Mat foundations for the treatment trains were completed in September 2002.

- Erection of the two 250,000 gallon storage tanks was completed by the end ofOctober 2002.

- The GWTP slab was completed in October 2002

The ion exchange system Process and Instrument Diagram (P&ID) shopdrawings were approved in October 2002.

Installation of the buried HOPE pipeline was completed in November 2002.

Erection of the GWTP building structural frame was completed in November2002.

All of the well house enclosures were set in November 2002.

Arrangement shop drawings for the treatment trains were approved in lateNovember 2002.


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- The GWTP building skin was completed to make the building weather tight inDecember 2002 allowing installation of welded process piping and pumps tobegin.

The first ion exchange train was delivered and set in place in January 2003.The second train was delivered and set in February.

- The welded process piping in the GWTP was completed in February 2003.

The two PLC systems were installed in February 2003 and testing began latein the month.

Subsystems testing began in March 2003.

Operator training began in March 2003 and concluded in June 2003.

All subsystem testing was complete by the end of April 2003. A shorttreatment trial was completed in early June 2003.

Substantial completion was achieved in early June and the final performancetest was begun on June 13, 2003.

- The final performance test was completed on July 18,2003.

- Final completion (except for one punch list item) was achieved in earlyAugust 2003.

- The USEPA completed the final inspection on August 12, 2003. The newfacility was turned over to the USEPA long term operator (The City of Colby)that same day.

- Operation of the system by the City of Colby for long term remediation beganat 9:00 am on August 12, 2003.

A more complete summary of construction progress on a month by month basis is

provided in the monthly construction progress reports included in Appendix F. Thesereports also summarize progress on submittals, problems encountered, and provide a brief

schedule analysis.

5.2 Construction Health and Safety

BVSPC prepared a Health and Safety program for the project (BVSCP 2001 a)

which was included in FHl's subcontract. All work conducted was done in accordance

with the BVSCP HSP. In addition, FHI prepared a detailed construction HSP which was

approved by the BVSPC manager of health and safety. FHI had a full time safety officer

at the site throughout the project. The BVSCP resident inspector for the project was a

trained health and safety expert. The BVSPC construction manager also conducted a

safety audit during the project to assure that proper methods were used and proper


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documentation was kept.

A job hazard analysis (JHA) was prepared for each task prior to beginning work.

The JHA listed the hazards of each task, the methods to mitigate these hazards and the

appropriate personal protective equipment (PPE) needed. Each JHA was numbered for

reference purposes. Copies of the JHA's prepared for the project are included in

Appendix G. The daily reports prepared by FHI (Appendix D) included a reference JHA

number for each type of work done that day. Prior to beginning any new task a

preparatory meeting was held including all the involved lower tier subcontractors. The

applicable JHA's were reviewed in the preparatory meetings.

A safety briefing was conducted at the beginning of each day. All people on site

that day were required to attend the safety briefing and sign an attendance form. The

safety briefing covered the key safety concerns for the work scheduled that day and

reviewed any safety related issues that may have arose the day before.

All subcontractor and lower tier subcontractor personnel were required to have a

pre-employment drug screen. Random drug screens were conducted throughout the

project. All on-site personnel were subject to random drug screens. The BVSPC and

FHI HSP's required drug testing for anyone involved in a workplace accident. All drug

screens conducted throughout the project were negative.

Health and safety was made the first priority for all activity throughout the job.

The extensive planning, thorough execution of the HSP requirements along with the

continual focus on safety contributed to an exceptional safe project. In total, over 39,000

site man-hours were worked with zero recordable injuries or lost time accidents.

Throughout the entire project only two first aids were required. Both were finger cuts

requiring only a Band-Aid.

5.3 Testing and Start-up

As the construction neared completion and prior to any overall system

performance tests, all subsystems and individual components were tested and any defects

found were corrected. Subsystem and component testing included the following:

Pipe leak testing- Pump tests for all pumps in the system- Valve and instrument function tests- Control/PLC systems function and logic tests- Testing and verification of all control interlocks, and alarms- Resin transfer system tests- Chlorine system tests

Complete plant hydraulic tests.

G WTS RA Report 5-3 46129.150RAC VII Ace Services Site September 2003

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- Compressed air and utility systems tests

A significant amount of time was required to test and de-bug the PLC systems

control logic. Ultimately the PLC systems were tested function by function in the field to

find and correct all logic, hardware and instrument problems prior to start-up.

Once all plant and well field components and systems were tested, and proper

function and control verified, a short duration treatment test was conducted to verify that

the ion exchange resin beds provided adequate hexavalent chrome removal. This test was

successful on the first attempt demonstrating that the plant could remove hexavalent

chrome to undetectable levels (less than 1 ug/1).

The subsystem, component and short duration treatment trials were intended to

trouble shoot any problems with the new installation and verify that everything works as

it should. A final treatment performance test was conducted as a continuous long

duration (35 days) test mimicking actual long-term operation. The primary objectives of

this test were as follows:

Demonstrate that the extraction wells can support design pumping rateswithout cycling.Demonstrate that the treatment process reliably achieves the required effluentquality under continuous, 24 hour per day operation.Demonstrate that the treatment process provides the required effluent qualityover the entire specified range of flows.

- Determine the amount of water that can be treated by the lead bed beforesignificant break through of hexavalent chrome occurs (the chrome holdingcapacity of the ion exchange resin).Determine the chrome break through characteristics of the resin in thisapplication (abrupt or gradual).Produce chrome saturated resin for TCLP testing to determine disposalrequirements for long term operation.

- Demonstrate that the plant requires minimal operator interface to run reliably.

The Groundwater Treatment System Final Performance Test began on June 13

2003 and was been successfully completed on July 18, 2003. All test objectives were

met. Complete details and results from the test are included in the Final Performance

Test Report (BVSPC 2003b). The test results support the following conclusions:

- With the exception of shallow well EX-2S, the extraction wells can supportpumping rates in excess of the design flow rates without cycling. This willallow pumping rates to be increased as needed to enhance plume control andaccelerate remediation of the aquifer.

- The ion exchange treatment process can continuously produce effluent qualitysubstantially better than the required discharge limit of 17 ug/1 hexavalent


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chrome and 100 ug/1 total chrome. The test data demonstrate that the systemcontinuously achieves an effluent quality of less than 1 ug/1 total chrome.

- The new treatment plant can treat up to 1100 gpm with absolutely nodegradation in the quality of the plant effluent.

The new treatment system requires very little operator interface to runreliably. The system ran continuously for 35 days with no down time.

- The type II strong base anion resin used in the process has a hexavalentchrome holding capacity in excess of 121 grams per cubic foot of resin in thisapplication. This provides for treatment of more than 20 million gallons ofwater per 560 cubic foot bed (25 million gallons at an influent concentrationof0.7mg/l).

- The hexavalent chrome breakthrough characteristic for the resin is gradualproviding several days from the first signs of breakthrough until the beds needto be advanced.

Following the conclusion of the performance test, the chrome-saturated resin in

the lead beds was removed and replaced with virgin resin. A sample of the spent resin

was analyzed via TCLP. TCLP results showed that the spent resin did not require

handling and disposal as a hazardous waste.

Overall, the performance of the system exceeded expectations and requirements.

In total, the treatment system processed over 42 million gallons of extracted ground water

in a 35-day period with essentially zero chrome in the effluent. The new system has

demonstrated perfect reliability with respect to effluent hexavalent chrome levels

throughout the extended test. No tendency for channeling or short-circuiting in the resin

beds was noted. The test demonstrated that the lead beds alone remove hexavalent

chrome to well below drinking water limits for 30 days in continuous operation. This

leaves the lag bad as a fully redundant backstop to insure that no measurable level ofhexavalent chrome is discharged from the plant.

5.4 Construction Subcontract Change Orders

Through the course of the construction project a total of 14 change orders to

FHI's subcontract were executed. These change orders were generally for additions that

enhanced the overall performance of the systems. Some were deducts from the

subcontract to account for work not needed or not done. The change orders are

summarized below:


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CO #1 - Extended the depth of extraction wells EX-4I and EX-5I and increasedthe size of these two extraction pumps to expand the well field capture zone.(Add $6,225.00)

CO #2 - Added protective bollards for the comer of the building due to excessivetraffic. (Add $900.00)

CO #3 - Added Plugging and abandoning the KDHE monitoring well in thevicinity of the old gas station. The well was no longer needed by KDHE and itwas an interference in the GWTP parking area. (Add $2,205.00)

CO #4 - Added resin traps to the discharge pipe from all six ion exchange vessels.(Add $10,185.55)

CO #5 - Added a 560 cubic foot resin transfer vessel with necessary foundations,piping and controls. The transfer vessel allows for resin exchange with a singletanker thereby reducing O&M costs. (Add $74,155.30)

CO #6 - Added an oil/water separator to the truck bay storm sewer line. This wasdone at the request of the City of Colby. (Add $ 1,950.00)

CO #7 - Added replacing the existing concrete block building at extraction wellPWS-8 with a new pre-fabricated enclosure. The existing structure wasdetermined to be unsound. (Add $21,472.00)

CO #8 - (Deduct Change Order). This change order reduced the amount of FHI'ssubcontract to compensate USEPA for additional time spent by BVSPC toprovide engineering support to FHI. (Deduct $15,207.04)

CO #9 - Added a flow meter to the potable water line entering the plant. Thismeter was added at the request of the City of Colby. (Add $2,335.00)

CO #10 - (Deduct Change Order). This change order reduced the amount ofFHI's subcontract to compensate USEPA for BVSPC's assistance to FHI withpreparation of the GWTS Operation & Maintenance Manuals. (Deduct$18,000.00)


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CO #11 - Added provision of furniture including desks, chairs, credenzas, filingcabinets and bookcases to fully outfit the GWTP office. (Add $3,750.00)

CO #12 - Added a chlorine mixing loop, upgrading the GWTP office and storagecloset siding material and providing fire extinguishers. (Add $7,916.62)

CO #13 - Added additional pipe supports in the GWTP. (Add $ 9,680.00)

CO #14 - (Net Deduct Change Order). Extended the final performance test by 5days, added surveying existing monitoring wells, added concrete barriers fortraffic protection at well nest EX-2, added full size sample refrigerator, added firstaid kits and deducted credit for ion exchange resin not needed due to revision infinal test procedures. (Deduct a net $71,947.27)

The financial impact to the project of all 14 change orders was a net addition of

$35,620.16. This is less than 1 percent of the original subcontract value of $5.68 million.

5.5 Problems Encountered and Met

Each monthly construction progress report prepared by BVSPC and submitted to

the USEPA (see Appendix F) included a description of problems encountered and

resolutions to those problems. The items listed below describe the most significant

challenges. See Appendix F for more details.

1. FHI did not have a schedule expert on staff with sufficient qualifications for thisproject. This is not uncommon for small business construction contractors. FHIintended to retain the services of a scheduling consultant as a lower tier subcontractor.Despite a significant investment of time, the first schedule consultant retained by FHIwas not able to produce a viable schedule with the required level of detail. BVSPCrecommended a firm that specializes in construction scheduling to FHI with whichBVSPC had substantial experience. FHI subsequently retained the services of therecommended firm. Due to the time lost on the first schedule consultant, FHI was notable to submit an acceptable initial schedule for about two months after notice toproceed. This put the project many weeks behind.

2. FHI proved to have insufficient technical and engineering expertise for a project ofthis complexity. This was due in part to the resignation early in project of theindividual that had prepared FHI's technical process proposal. This was a significantloss to FHI and it occurred shortly after notice to proceed. This shortcoming was


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addressed by BVSPC providing technical engineering support to FHI. USEPA wascompensated for this via a deduct change order reducing the value of the FHIsubcontract (see CO # 8 and CO #10 above).

The results of ground water sampling efforts in the spring of 2002 indicated that thechromium plume had rapidly migrated to the east and south in the deep aquifer zone.The extraction system design, which had been completed in January 2002 (beforethese results were available), did not include deep zone extraction wells at thesoutheast most reach of the well field. The problem was resolved at minimal cost(see change order CO #1 above) by increasing the depth and pumping rates ofintermediate wells EX-4I and EX-5I. These two wells were drilled and screened todraw water from both the intermediate and deep aquifer zones. This provided asufficient expansion of the deep capture zone to the south and east to control theexpanded plume. No increase in the size of the HDPE collection piping was neededsince the possible need to expand well field flow was anticipated in the design.

4. There were numerous challenges concerning fabrication and delivery of the ionexchange treatment trains. US Filter (USF) was the lower tier subcontractorresponsible for fabrication, delivery and installation of the ion exchange trains. USFwas late in producing the required P&ID's and train arrangement drawings forapproval and was on a very late track for fabrication and delivery of the trains. Thiswas due in part to FHI's difficulty in communicating the technical needs of theproject to USF. In addition there were some disagreements between FHI and USFregarding the terms of the lower tier subcontract. BVSPC eventually began tocommunicate directly with USF to expedite progress and meetings were held toclarify the contract issues. Although these efforts sped up fabrication of the trains,delivery to the job site was still about 2 months later than scheduled.

5. During the early stages of the construction job, FHI was having serious cash flowdifficulties and were temporarily unable to meet all of their short-term financialobligations. As a result, FHI fell behind on payments to lower tier subcontractors andsuppliers. Eventually some of the lower tier subcontractors refused to continue workuntil payments were made thereby further delaying the project. When BVSPCbecame aware of the delinquent payments immediate action was taken to protect theUSEPA's financial interests. BVSPC facilitated the creation of a schedule for catch-up payments to the lower tier subs and began directing the distribution of all futurepayment made to FHI to the appropriate subcontractors and suppliers. BVSPC'sdirection of FHI's funds distribution began in January 2003 and continued throughthe end of the job. Further delays to project were thereby avoided.

6. FHI fell behind the required project schedule right at the beginning of the project (seeitem 1 above). The job continued to slip further behind for a variety of reasons, manyof which are noted above. Efforts to reduce schedule slippage other than those noted


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above included expedited reviews of all time critical shop drawings, agreements withsuppliers for expedited deliveries, extra FHI personnel on site and additional supportfrom BVSPC to FHI. In addition, the job went on a six day per week work schedule(including Saturdays) in July 2002. Beginning in August 2002, this was expanded toinclude some Sundays as well. This continued for the remainder of the job.Although the efforts to accelerate progress could not bring the job back on theoriginal BVSPC schedule, construction completion (achieved on August 12, 2003)was still well ahead of the USEPA target date of September 30, 2003.

5.6 Lessons learned

Construction of the ACE Services site remedy was successfully completed in

accordance with the requirements of the amended ROD and all technical design

documents. The demonstrated performance of completed facility exceeded all

requirement and expectations. An important contribution to this success was the

excellent communication between all parties including the USEPA, BVSPC and FHI.

The cooperation and support of the USEPA throughout the project was a key element in

this success.

There were virtually no issues or problems with the engineering design, drawings

or specifications for the project that arose during the course of construction. Everything

went in and worked as planned. The lessons learned form this project stem mostly from

contracting issues related to small businesses. The following observations may have

relevance or applicability to other remediation projects:

- A project of this size and technical complexity is a poor fit for most smallbusiness construction contractors. These firms are not typically large enoughto have discipline engineering staff with significant experience in largetreatment system, PLC based control systems, Fiber optic communicationsystems, etc. It was extremely difficult to find qualifying small businesses toeven bid this project. All but two of the five invited declined to bid due to thesize and complexity or the project. When contracting with a small businessfor a job of this nature, extra schedule time and engineering support should beplanned.

- The original concept for long term operation of the facility included havingthe exhausted (chrome saturated) ion exchange resin hauled to an off-sitefacility for regeneration. The same resin would then be placed back in the ionexchange vessels and used again. This cycle would continue indefinitely. Itwas found during the project that the cost of fresh virgin resin of the type usedat the GWTP has come down recently such that using virgin resin at eachexchange is more cost effective than off-site regeneration of the resin. Thelong-term resin service contract obtained by the City of Colby wassubsequently based on providing virgin resin for each exhaustion cycle.


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6.0 Certification that Remedy is Operational and Functional

Based on the results obtained from the final performance test (BVSPC 2003b), all

the subsystem and component tests as well as the visual observation during the Final

Inspection, the new ground water extraction and treatment system is fully complete. The

remedial construction efforts at the ACE Services in Colby, Kansas were performed in

accordance with the requirements of the amended ROD and all the design documents.

BVSPC certifies that the remedy is operational and functional.

The As-Constructed drawings are too voluminous to attach to this report. Copies

of these drawings have been provided to the USEPA. Copies of all As-Built documents

are kept on file in the new GWTP office for reference.

All systems and equipment in the new GWTS are warranted by FHI for one year

from Final Acceptance. This warranty will be in force through August 11, 2004.

GWTS RA Report 6-1 46129.150RAC Vll Ace Services Site September 2003

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7.0 Operation and Maintenance

Operation of the new ground water extraction and treatment system is expected to

be required for 13 years to remediate the entire chrome plume to below the clean up goal

of less than 100 ug/1 total chrome. The USEPA is responsible for the first 10 years of

system operation. Beyond 10 years, the responsibility falls to the KDHE. The City of

Colby Public Works Department is operating the system on behalf of the USEPS via a

grant agreement. This provides both a stable local supply of plant staff as well as the

potential for continuity in operating staff when the transition to KDHE occurs, presuming

operation is required for that duration. Six of the Colby Public Works staff members

were trained in operation, monitoring and maintenance of the new system. Continuous

operation of the new GWTS by the City of Colby began on August 12,2003.

A detailed Operation and Maintenance Manual was prepared for the new GWTS.

This manual covers all equipment, subsystems and controls for the entire GWTS. The

manual provides detailed operating procedures, trouble shooting guides and detailed

vendor literature for all components and systems. The manual also provides system

sampling and monitoring requirements as well as all documentation required to verify

and record system performance. The O&M Manual was used extensively in training the

plant operators.

The USEPA has assigned BVSPC a Long Term Remedial Action (LTRA) work

assignment to monitor the progress of the aquifer remediation. Groundwater samples for

chromium analysis will be collected monthly from a selected group of monitoring wells

and extraction wells and water levels will be measured monthly throughout the area. In

addition groundwater samples will be collected quarterly from all the monitoring,

residential and extraction wells in the area. These routine measurements will allow closetracking of chromium plume and evaluation of the efficiency of the extraction system as

well as verification that the entire plume is captured. Any adjustments of extraction well

flows needed based on analysis of the collected data will be made as necessary to ensure

plume capture and to improve the efficiency of the overall system.

The LTRA Work Assignment (075-RARA-07GE) also allows for direct

assistance from BVSPC to the City of Colby to help with operational problems and

challenges on an as needed basis. In addition, under the LTRA Work Assignment

BVSPC will perform periodic audits of the City's operation to assure that requirements

are met.


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8.0 Summary of Project Costs

• The final cost for the construction project was $5,720,088.02 including

$35,620.16 net in change orders. The engineer's estimate of construction cost was• $6,189,447.00. Table 8-1 presents a summary of construction phase costs.

Table 8-1

Cost Summary

ACE Services Site Remedial Construction

Engineer's Estimate $6,189,447.00

I FHI Bid $5,684,467.86

Net Change Orders $ 35.620.16

Total Construction Phase Cost $5,720,088.02


II 9.0 Bibliograghy

• BVSPC 2001 a, Construction Health and Safety Program, A CE Services Site, Colby,• Kansas, contained within the Final Specifications and Contract Documents, ACE

Services Site, Colby, Kansas, Volume 1, prepared for USEPA Region Vll, September 21,I 2001.

I BVSPC 2002a, Remedial Action, Quality Assurance Project Plan, ACE Services Site,• Colby, Kansas, prepared for USEPA Region VII, March 2002.

• BVSPC 2002b, Remedial Action, Field Sampling Plan, ACE Services Site, Colby,Kansas, prepared for USEPA Region VII, March 2002.

BVSPC 2002c, Construction Management and Quality Assurance Plan, ACE ServicesI Site, Colby, Kansas, prepared for USEPA Region VII, February 2002.

I BVSPC, 2003a, Remedial Action Report, Demolition Summary, Final, ACE Services Site,• prepared for USEPA Region VII, September 5, 2003.

• BVSPC, 2003b, Final Treatment Performance Test Report, ACE Services Site, preparedfor USEPA Region VII, September 2003.

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GWTSRA Report 9-1 46129.150_ RAC Vll Ace Services Site September 2003